# 2021 NJ NG Program Evaluation - nj-2021-gas-program-evaluation (New Jersey; Natural Gas State Program Evaluation)

- **operation:** document
- **citation:** PHMSA nj-2021-gas-program-evaluation
- **title:** 2021 NJ NG Program Evaluation - nj-2021-gas-program-evaluation (New Jersey; Natural Gas State Program Evaluation)
- **source type:** inspection
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-01-01
- **effective on:** Not available
- **summary:** 2021 PHMSA natural gas program evaluation for New Jersey.
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- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2023-06/nj-2021-gas-program-evaluation.pdf
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1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2021 Gas State Program Evaluation for NEW JERSEY BOARD OF PUBLIC UTILITIES Document Legend PART: O -- Representative, Dates and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- State Qualifications D -- Program Performance E -- Field Inspections F -- Damage prevention and Annual report analysis G -- Interstate Agent/Agreement States DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 1

2021 Gas State Program Evaluation -- CY 2021 Gas State Agency: New Jersey Rating: Agency Status: Date of Visit: 07/12/2022 - 07/14/2022 Agency Representative: Mr. Juan Urena Acting Program Manager PHMSA Representative: Clint Stephens State Liaison Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Joseph L. Fiordaliso, President Agency: New Jersey Board of Public Utilities Address: 44 South Clinton Avenue City/State/Zip: Trenton, New Jersey 08625 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Evaluator Guidance for conducting state pipeline safety program evaluations. The evaluation should generally reflect state program performance during CY 2021 (not the status of performance at the time of the evaluation). A deficiency in any one part of a multiple-part question should be scored as “Needs Improvement.” Determine the answer to the question then select the appropriate point value. If a state receives less than the maximum points, include a brief explanation in the appropriate notes/comments section. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and they OBJECTIVELY reflect the state's program performance for the question being evaluated. Increasing emphasis is being placed on how the state pipeline safety programs conduct and execute their pipeline safety responsibilities (their performance). This evaluation, together with selected factors reported in the state's annual progress report attachments, provide the basis for determining the state's pipeline safety grant allocation. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 0 0 B Program Inspection Procedures 15 15 C State Qualifications 10 10 D Program Performance 50 42 E Field Inspections 15 15 F Damage prevention and Annual report analysis 10 10 G Interstate Agent/Agreement States 0 0 TOTALS 100 92 State Rating................................................................................................................................................... 92.0 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 2

PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Were the following Progress Report Items accurate? (*items not scored on progress report) Info Only = No Points a. Stats On Operators Data - Progress Report Attachment 1 b. State Inspection Activity Data - Progress Report Attachment 2 c. List of Operators Data - Progress Report Attachment 3* d. Incidents/Accidents Data - Progress Report Attachment 4* e. Stats of Compliance Actions Data - Progress Report Attachment 5* f. List of Records Kept Data - Progress Report Attachment 6 * g. Staff and TQ Training Data - Progress Report Attachment 7 h. Compliance with Federal Regulations Data - Progress Report Attachment 8 i. Performance and Damage Prevention Question Data - Progress Report Attachment 10* Evaluator Notes: 1a. The data in Attachment 1 of Progress Report seems accurate. 1b. The data in Attachment 2 of Progress Report seems accurate. 1c. The data in Attachment 3 of Progress Report seems accurate. 1d. The information in Attachment 4 of Progress Report was verified in PDM. 1e. The information in Attachment 5 of Progress Report was accurate. 1f. The information in Attachment 6 of Progress Report seems accurate. 1g. The information in Attachment 7 of Progress Report was verified in TQ Blackboard. 1h. The information in Attachment 8 of Progress Report is accurate. 1i. The information in Attachment 10 of the Progress Report is accurate. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 3

PART B - Program Inspection Procedures Points(MAX) Score 1 Do written procedures address pre-inspection, inspection and post inspection activities for each of the following inspection types: Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard Inspections, which include Drug/Alcohol, CRM and Public Awareness Effectiveness Inspections b. TIMP and DIMP Inspections (reviewing largest operator(s) plans annually) c. OQ Inspections d. Damage Prevention Inspections e. On-Site Operator Training f. Construction Inspections (annual efforts) g. LNG Inspections Evaluator Notes: The procedures were in Section 7.4 - Inspection Procedures, pages 17-20. 5 5 2 Do written procedures address inspection priorities of each operator, and if necessary each unit, based on the following elements and time frames established in its procedures? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Length of time since last inspection b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) c. Type of activity being undertaken by operators (i.e. construction) d. Locations of operator's inspection units being inspected - (HCA's, Geographic area, Population Centers, etc.) e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Operators and any Other Factors) f. Are inspection units broken down appropriately? Evaluator Notes: The procedures were in Section 7.2 - Inspection Priorities, page 16. 4 4 3 (Compliance Procedures) Does the state have written procedures to identify steps to be taken from the discovery to resolution of a probable violation? Chapter 5.1 Yes = 3 No = 0 Needs Improvement = 1-2 a. Procedures to notify an operator (company officer) when a noncompliance is identified b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns c. Procedures regarding closing outstanding probable violations Evaluator Notes: The procedures were in Section 8 ? Post Inspection Evaluation and Enforcement, pages 21-24. 3 3 4 (Incident/Accident Investigations) Does the state have written procedures to address state actions in the event of an incident/accident? Yes = 3 No = 0 Needs Improvement = 1-2 a. Mechanism to receive, record, and respond to operator reports of incidents, including after-hours reports b. If onsite investigation was not made, do procedures require on-call staff to obtain sufficient information to determine the facts to support the decision not to go on-site. Evaluator Notes: The Procedure were in Section 9 - Incident Investigation Procedures, pages 24-27. 3 3 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 4

5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part B of the program evaluation. DUNS: 189737682 2021 Gas State Program Evaluation Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 5

PART C - State Qualifications Points(MAX) Score 1 Has each inspector and program manager fulfilled training requirements? (See Guidelines 5 5 Appendix C for requirements) Chapter 4.3 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead b. Completion of Required DIMP/IMP Training before conducting inspection as lead c. Completion of Required LNG Training before conducting inspection as lead d. Root Cause Training by at least one inspector/program manager e. Note any outside training completed f. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector (Reference State Guidelines Section 4.3.1) Evaluator Notes: The NJBPU has inspectors/program manager qualified based on fulfilling training requirements to lead different types of inspections. 2 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Yes = 5 No = 0 Needs Improvement = 1-4 5 5 Evaluator Notes: Yes. The state pipeline safety program manager has adequate knowledge of PHMSA program and regulations. 3 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part C of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 6

PART D - Program Performance Points(MAX) Score 1 Did state inspect all types of operators and inspection units in accordance with time 5 3 intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction (did state achieve 20% of total inspection person-days?) g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) Evaluator Notes: Reviewed the following inspection records: Standard: Public Service Electric & Gas Co. ? Regulator (10/29/21 & 12/11/20), Public Service Electric & Gas Co. Transmission ? Corrosion (3/2/22), South Jersey Gas Co. LNG (12/2/21 & 12/5/18), Elizabeth Gas Co. LPG (Discovered in 2020), Public Service Electric and Gas Co. (Discovered in 2020), Cypress Gardens Apts (12/5/19), Community Service Group (11/20/18 due in 2021), Dovan Management Group (12/6/21 & 12/5/18), Greater Englewood Housing Corp. (11/17/21 & 12/6/17 did not meet interval), Georgetown Apts. ( 12/27/21 & 12/18/18), Lodi Housing Authority (9/29/21 & 11/14/18); PA: Public Service Electric & Gas Co. Distribution/Transmission (12/20/21 & 2012 did not meet interval), South Jersey Gas Co. LNG (12/2/21 & 12/5/18); D&A: Public Service Electric & Gas Co. Distribution/Transmission (12/8/21 & 5/28/15 did not meet interval), South Jersey Gas Co. LNG (12/14/21 & 12/2/14 did not meet interval); CRM: South Jersey Gas Co. LNG (12/2/21 & 12/5/18); OQ: Public Service Electric & Gas Co. Distribution/Transmission (12/28/18), South Jersey Gas Co. LNG (12/2/21 & 12/5/18); and DIMP: Public Service Electric & Gas Co. (12/18/19), Public Service Electric & Gas Co. Transmission (12/30/21 & 12/20/17). 2 Did inspection form(s) cover all applicable code requirements addressed on Federal Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1. Do inspection records indicate that adequate reviews of procedures, records and field activities, including notes and the appropriate level of inspection person-days for each inspection, were performed? Yes = 10 No = 0 Needs Improvement = 1-9 a. Standard (General Code Compliance) b. Public Awareness Effectiveness Reviews c. Drug and Alcohol d. Control Room Management e. Part 193 LNG Inspections f. Construction g. OQ (see Question 3 for additional requirements) h. IMP/DIMP (see Question 4 for additional requirements) 10 7 Evaluator Notes: Reviewed the following reports: (1) Standard - Public Service Electric & Gas Co. ? Regulator (10/29/21), South Jersey Gas Co. LNG (12/2/21) N/A not documented and form not filled out completely, Dovan Management Group (12/6/21) form not filled out completely, Greater Englewood Housing Corp. (11/17/21), Georgetown Apts. (12/27/21 still open), Lodi Housing Authority (9/29/21); (2) PA - Public Service Electric & Gas Co. Distribution/Transmission (12/20/21 only procedures inspected, but did not fill in form N/C for records portion), South Jersey Gas Co. LNG (12/2/21 only procedures inspected, but did not fill in form N/C for records portion); (3) D&A - Public Service Electric & Gas Co. Distribution/Transmission (12/8/21) and South Jersey Gas Co. LNG (12/14/21 only procedures inspected, not records), (4) OQ - South Jersey Gas Co. LNG (12/2/21); and IMP - Public Service Electric & Gas Co. Transmission (12/30/21). DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 7

3 Is state verifying monitoring (Protocol 9/Form15) of operators OQ programs? This should include verification of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals established in the operator's plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: Reviewed inspection report for South Jersey Gas Co. LNG (12/2/21). No issue. 2 2 4 Is state verifying operator's integrity management Programs (IMP and DIMP)? This should include a review of plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operator's plan(s). 49 CFR 192 Subparts O and P Yes = 2 No = 0 Needs Improvement = 1 a. Are the implementation plans of the state's large/largest operators(s) being reviewed annually to ensure they are completing full cycle of the IMP process? b. Are states verifying with operators any plastic pipe and components that have shown a record of defects/leaks and mitigating those through DIMP plan? c. Are the states verifying operators are including low pressure distribution systems in their threat analysis? Evaluator Notes: Reviewed inspection report for Public Service Electric & Gas Co. Transmission (12/30/21 not completed). 2 1 5 Did the state review the following (these items are NTSB recommendations to PHMSA 2 2 that have been deemed acceptable response based on PHMSA reviewing these items during the evaluation process): Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 a. Operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken; b. Operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance); c. Operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21; d. Operator records of previous accidents and failures including reported third- party damage and leak response to ensure appropriate operator response as required by 192.617; e. Directional drilling/boring procedures of each pipeline operator or its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies; f. Operator procedures for considering low pressure distribution systems in threat analysis? g. Operator compliance with state and federal regulations for regulators located inside buildings? Evaluator Notes: 5a. This item is listed in NJBPU Form GS-2 on page 2-3. NJBPU also added this question to the construction inspection forms, GS-9-ST & GS-9-PL. 5b. This item is listed in NJBPU Form GS-3 page 1, under B 4. 5c. This item is listed in NJ BPU Form GS-3 on page 2, B 8 (7). 5d. This item is listed in NJBPU Form GS-3 on page 3, B10. 5e. This item is included in the New Jersey Administrative Code Section 14:7-1.25 5f. The NJBPU has been discussing low pressure distribution systems in their DIMP inspections as being included in the threat analysis. This is included in form GS-35 inspection form, question 4. 5g. The NJBPU has been discussing with operators about having regulators located outside of buildings. There are numerous meter sets inside buildings in New Jersey, so an email was sent to each operator on 8/28/20 pertaining to this issue. Recommended the NJBPU communicate with operator on an annual basis. DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 8

6 Did the State verify Operators took appropriate action regarding advisory bulletins issued since the last evaluation? (Advisory Bulletins Current Year) Yes = 1 No = 0 Needs Improvement = .5 1 1 Evaluator Notes: The NJBPU has included discussion with operators about ADBs in the DIMP inspections. Also, ADBs are sent to the operators through email. 7 (Compliance Activities) Did the state follow compliance procedures (from discovery to 10 8 resolution) and adequately document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 10 No = 0 Needs Improvement = 1-9 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? b. Were probable violations documented properly? c. Resolve probable violations d. Routinely review progress of probable violations e. Did state issue compliance actions for all probable violations discovered? f. Can state demonstrate fining authority for pipeline safety violations? g. Does Program Manager review, approve and monitor all compliance actions? (note: Program Manager or Senior Official should sign any NOPV or related enforcement action) h. Did state compliance actions give reasonable due process to all parties? Including "show cause" hearing, if necessary. i. Within 30 days, conduct a post-inspection briefing with the owner or operator outlining any concerns j. Within 90 days, to the extent practicable, provide the owner or operator with written preliminary findings of the inspection. (Incident investigations do not need to meet 30/90-day requirement) Evaluator Notes: There was no compliance action against Greater Englewood Housing Corp. (11/17/21) standard inspection. There has been no enforcement letter sent to Public Service Electric & Gas Co. Distribution/Transmission (12/8/21) D&A inspection ? last communication with operator by email was 2/11/22. 8 (Incident Investigations) Were all federally reportable incidents investigated, thoroughly documented, with conclusions and recommendations? Yes = 10 No = 0 Needs Improvement = 1-9 a. Does state have adequate mechanism to receive and respond to operator reports of incidents, including after-hours reports? b. Did state keep adequate records of Incident/Accident notifications received? c. If onsite investigation was not made, did the state obtain sufficient information from the operator and/or by means to determine the facts to support the decision not to go on site? d. Were onsite observations documented? e. Were contributing factors documented? f. Were recommendations to prevent recurrences, where appropriate, documented? g. Did state initiate compliance action for any violations found during any incident/accident investigation? h. Did state assist Region Office or Accident Investigation Division (AID) by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? i. Does state share any lessons learned from incidents/accidents? 10 10 Evaluator Notes: Reviewed incident reports included in Attachment 4 of the Progress Report with those incidents where they decided not to go on site, documentation was adequate between the state and the operator. There was one onsite incident investigation (Public Service Electric & Gas Co. ? 5/11/21) by which the state obtained sufficient information from the operator to determine root cause. The state has letter with AG recommending civil penalty to the operator. DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 9

9 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: Chair letter sent December 1, 2021, received response on February 1, 2022. No issue. 1 1 10 Did State conduct or participate in pipeline safety training session or seminar in Past 3 Years? Chapter 8.5 Info Only = No Points Evaluator Notes: The NJBPU had last pipeline safety seminar in 2019. Working on scheduling seminar for 2022. Info Only Info Only 11 Has state confirmed transmission operators have submitted information into NPMS database along with changes made after original submission? Info Only = No Points Evaluator Notes: This information is documented in the GS-3 inspection form, section E, #4, page 9. Info Only Info Only 12 Does the state have a mechanism for communicating with stakeholders - other than state 1 1 pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NJBPU is communicating with its stakeholder through the quarterly LDC (GDC meeting) with the operators, and public hearings pertaining to penalty cases are recorded to YouTube. Contact information for pipeline safety staff is on the state website. 13 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NJBPU has no open SRC Reports. 1 1 14 Was the State responsive to: 1 1 Yes = 1 No = 0 Needs Improvement = .5 a. Surveys or information requests from NAPSR or PHMSA; and b. PHMSA Work Management system tasks? Evaluator Notes: Yes. The NJBPU was responsive to surveys and/or information requests from NAPSR or PHMSA. Keeps survey folder in Outlook. The NJBPU had no WMS tasks in 2021. 15 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The NJBPU has no open waivers/permits for any operator. 1 1 16 Were pipeline program files well-organized and accessible? Info Only = No Points Evaluator Notes: Yes. Files are well organized and stored in the pipeline safety database. DUNS: 189737682 2021 Gas State Program Evaluation Info Only Info Only New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 10

17 Discussion with State on accuracy of inspection day information submitted into State Inspection Day Calculation Tool (SICT). Has the state updated SICT data? Yes = 3 No = 0 Needs Improvement = 1-2 3 3 Evaluator Notes: CY 2022. The NJBPU has no issues with the data submitted in the SICT tool. The state is in the process of preparing data to submit for 18 Discussion on State Program Performance Metrics found on Stakeholder Communication site.\ http://primis.phmsa.dot.gov/comm/states.htm?nocache=4805 Info Only = No Points Evaluator Notes: Discussed State Program Performance Metrics and found no negative trends for the CY 2021. Info Only Info Only 19 Did the state encourage and promote operator implementation of Pipeline Safety Management Systems (PSMS), or API RP 1173? This holistic approach to improving pipeline safety includes the identification, prevention and remediation of safety hazards. Info Only = No Points a. https://pipelinesms.org/ b. Reference AGA recommendation to members May 20, 2019 Info Only Info Only Evaluator Notes: The larger operators within the NJBPU jurisdiction have started implementing some form of the Pipeline Safety Management System. The state will continue to monitor the progress toward completion of implementation. 20 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: The following issues were identified in Part D of the program evaluation: (1) The NJBPU did not inspect all types of operators and inspection units in accordance with time intervals; (2) The NJBPU did not complete all applicable portions of inspection forms; (3) The NJBPU is not verifying all operator's integrity management programs; and (4) The NJBPU did not follow compliance procedures from discovery to resolution and adequately document all probable violations. Total points scored for this section: 42 Total possible points for this section: 50 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 11

PART E - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative (enter specifics into the comments box below) Info Only = No Points a. What type of inspection(s) did the state inspector conduct during the field portion of the state evaluation? (i.e. Standard, Construction, IMP, etc) b. When was the unit inspected last? c. Was pipeline operator or representative present during inspection? d. Effort should be made to observe newest state inspector with least experience Evaluator Notes: Operator: New Jersey Natural Gas Inspector(s): Andre Moses (L), Eric Weaver, John Grillo, and Juan Urena Location: Jackson, NJ Date: July 13, 2022 PHMSA Rep.: Clint Stephens Info Only Info Only The NJBPU conducted a construction inspection. The operator was replacing a section of 8" steel pipe. The pipeline operator was present during the inspection. 2 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The inspector used the GS-9 Field Construction Inspection form as a guide for the inspection. 2 2 3 Did the inspector adequately review the following during the inspection 10 10 Yes = 10 No = 0 Needs Improvement = 1-9 a. Procedures (were the inspector's questions of the operator adequate to determine compliance?) b. Records (did the inspector adequately review trends and ask in-depth questions?) c. Field Activities/Facilities (did inspector ensure that procedures were being followed, including ensuring that properly calibrated equipment was used and OQ's were acceptable?) d. Other (please comment) e. Was the inspection of adequate length to properly perform the inspection? Evaluator Notes: The inspectors reviewed welding procedures, welder qualifications, jeeping procedures, and coating removal/repair procedures. The inspectors observed welding, pipeline stamps (specs), welding rods, and welding voltage settings. There were no issues. 4 From your observation did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: From my observation the inspector had adequate knowledge of the pipeline safety program and regulations. 2 2 5 Did the inspector conduct an exit interview, including identifying probable violations? (If 1 1 inspection is not totally completed the interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: The inspector did not conduct an exit interview; however, the operator was communicated of any issues found at the time of discovery. DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 12

6 Was inspection performed in a safe, positive, and constructive manner ? Info Only = No Points a. No unsafe acts should be performed during inspection by the state inspector b. What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) c. Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) d. Other Info Only Info Only Evaluator Notes: The inspection was performed in a safe, positive, and constructive manner. The inspectors observed welding, jeeping, welding procedures, and construction specifications. The inspector performed the inspection adequately. 7 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part E of the program evaluation. Info Only Info Only Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 13

PART F - Damage prevention and Annual report analysis Points(MAX) Score 1 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues. Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: Yes. The state has reviewed Operator Annual reports, along with Incident/Accident reports for accuracy and analyzed data for trends and operator issues. 2 Has the state verified that the operators analyze excavation damages for the purpose of 2 2 determining root causes and minimizing the possibility of a recurrence? (192.617) Has the state verified that the operators have appropriately identified excavators who have repeatedly violated one-call laws and damaged their facilities. Have the operators taken steps to mitigate that risks? (192.1007) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: The NJBPU has verified that the operators analyze excavation damages for the purpose of determining root causes and minimizing the possibility of recurrence. The operators must report to the Bureau of One-Call those excavators who repeatedly damage their facilities. The NJBPU has discussed with the operators during the DIMP inspections the ways the steps the operator has taken to mitigate those risks. 3 Has the state reviewed the operator's annual report pertaining to Part D - Excavation 4 4 Damage? Yes = 4 No = 0 Needs Improvement = 1-3 a. Is the information complete and accurate with root cause numbers? b. Has the state evaluated the causes for the damages listed under "One-Call Notification Practices Not Sufficient" (Part D.1.a.)? c. Has the state evaluated the causes for the damages listed under "Locating Practices Not Sufficient" (Part D.1.b)? For each operator, does the state review the following? d. Is the operator or its locating contractor(s) qualified and following written procedures for locating and marking facilities? e. Is the operator appropriately requalifying locators to address performance deficiencies? f. What is the number of damages resulting from mismarks? g. What is the number of damages resulting from not locating within time requirements (no-shows)? h. Is the operator appropriately addressing discovered mapping errors resulting in excavation damages? i. Are mapping corrections timely and according to written procedures? j. Has the state evaluated the causes for the damages listed under "Excavation Practices Not Sufficient" (Part D.1.c.)? Evaluator Notes: The NJBPU is reviewing the operator's annual reports and evaluating causes for the damages listed under "one-Call Notification Not Sufficient", "Locating Practices Not Sufficient", and "Excavation Practices Not Sufficient". The New Jersey One Call Center tracks damages resulting from mismarks; locating within time requirements; mapping errors; and following written procedures. The information for reasons of excavation damages is discussed and recorded in the GS-35 DIMP inspection form. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? Yes = 2 No = 0 Needs Improvement = 1 a. What stakeholder group is causing the highest number of damages to the pipelines? Operator, contractor, locating company or public. b. Has the state verified the operator is appropriately focusing damage prevention education and training to stakeholders causing the most damages? 2 2 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 14

c. Has the state evaluated which of the following best describes the reason for the excavation damages; i.e., operator or contractor not following written procedures, failure to maintain marks, failure to support exposed facilities, failure to use hand tools were required, failure to test-hole (pot hole), improper backfilling practices, failure to maintain clearance or insufficient excavation practices. d. Has the state verified the operator is appropriately focusing damage prevention education and training to address the causes of excavation damages? Evaluator Notes: The NJBPU has collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests. The New Jersey One Call Center host a Damage Prevention Seminar for the public and excavators monthly. The information for reasons of excavation damages is discussed and recorded in the GS-35 DIMP inspection form. 5 General Comments: Info Only = No Points Evaluator Notes: There were no issues identified in Part F of the program evaluation. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 15

PART G - Interstate Agent/Agreement States Points(MAX) Score 1 Were all inspections of interstate pipelines conducted using the Inspection Assistant program for documenting inspections? Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. Info Only Info Only 2 If inspections were conducted independent of a PHMSA team inspection was notice of all Info Only Info Only identified probable violations provided to PHMSA within 60 days? Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. 3 If inspections were conducted independent of a PHMSA team inspection was PHMSA immediately notified of conditions which may pose an immediate safety hazard to the public or environment? Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. Info Only Info Only 4 If inspections were conducted independent of a PHMSA team inspection did the state coordinate with PHMSA if inspections not were not included in the PHMSA Inspection Work Plan? Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. Info Only Info Only 5 Did the state take direction from and cooperate with PHMSA for all incident investigations conducted on interstate pipelines? Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. Info Only Info Only 6 General Comments: Info Only = No Points Evaluator Notes: The NJBPU is not an interstate agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 189737682 2021 Gas State Program Evaluation New Jersey NEW JERSEY BOARD OF PUBLIC UTILITIES, Page: 16
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